US OFAC Russia SDN/sanctions expansions 2022

On 24 February 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control imposed expansive Russia-related measures under Executive Order 14024. The Treasury press release of that date records correspondent and payable-through account prohibitions on Public Joint Stock Company Sberbank of Russia (Directive 2) and full blocking sanctions on VTB Bank Public Joint Stock Company and named other institutions, together with Directive 3 debt-and-equity restrictions. OFAC FAQ 966 restates the same 22–24 February 2022 sequence: a financial-services sector determination on 22 February, Directive 2 and Directive 3 on 24 February, and blocking of specified Russian financial institutions including VEB, VTB, Otkritie, Promsvyazbank, Sovcombank and Novikombank. This Fact is the 2022 U.S. SDN/sanctions expansion wave as recorded by Treasury, not a unique frozen-asset coefficient and not a SWIFT Council Decision.

Context

E.O. 14024 (15 April 2021) already authorised Treasury, in consultation with State, to determine sectors of the Russian economy for sanctions. The 22 February 2022 financial-services sector determination opened that gate. The 24 February package followed Russia’s full-scale attack on Ukraine that morning and President Biden’s public announcement of financial costs. Joe Biden announced the political frame; OFAC wrote the directives. Antony Blinken held State. Vladimir Putin is the listed Russian principal in parallel EU and UK acts the same week; he did not author the OFAC directives.

Treasury said the 24 February measures targeted institutions holding nearly 80 percent of Russian banking assets. That percentage is Treasury’s contemporaneous characterisation in jy0608, not a measured change in Russian M2. Correspondent-account prohibitions on Sberbank were timed to take effect 26 March 2022. Full blocking of VTB was immediate as of the designation.

Further 2022 OFAC expansions — 11 March designations of named elites, 6 April blocking of Sberbank and additional persons, 8 May board-member designations — densify the same year’s SDN/sanctions file.

Keep 24 February 2022 OFAC directives off the EU 23–25 February Council packages and off the March SWIFT cut. Keep Directive 2’s March 26 effective date off the February designation date.

OFAC may designate persons and issue directives under IEEPA and E.O. 14024. That office cannot enact an EU CFSP Decision, disconnect a bank from SWIFT, or print a unique frozen-asset coefficient not in the Treasury instrument.

Why it matters

The 2022 OFAC expansions are the U.S. financial-sanctions densification at war onset: correspondent-account isolation of Sberbank, SDN blocking of VTB and named banks, and Directive 3 debt/equity limits. Interpretation of evasion, energy carve-outs, or later secondary measures lives on the impact path, not as a rant in this event record.